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Legislation
Corporation Tax Act 2010

Part 21B Group mismatch schemes

  • Section 938A Losses and profits from group mismatch schemes to be disregarded
  • Section 938B Meaning of “a group mismatch scheme” and “the scheme group”
  • Section 938C Meaning of “scheme loss” and “scheme profit”
  • Section 938D Meaning of “relevant tax advantage” etc and “the scheme period”
  • Section 938E Meaning of “group”
  • Section 938F Meaning of references to economic profits and losses
  • Section 938G Tax capacity assumption
  • Section 938H Meaning of “scheme”
  • Section 938I Schemes involving repos or quasi-repos
  • Section 938J Schemes involving finance arrangements
  • Section 938K Trading income
  • Section 938L Foreign companies and foreign permanent establishments
  • Section 938M Controlled foreign companies
  • Section 938N Priority
  1. Part 21B
  2. Controlled foreign companies

Section 938M | Controlled foreign companies

From legislation.gov.uk

(1)Section 371SL(1) of TIOPA 2010 (assumption that a CFC is not a member of any group for the purposes of any provision of the Tax Acts) does not apply for the purposes of this Part.

(2)References in this Part to a company bringing amounts into account, or not bringing them into account, as debits or credits for the purposes of Part 5 or 7 of CTA 2009 include bringing amounts into account, or not bringing them into account, as debits or credits under that Part in determining the assumed taxable total profits of the company (or in determining that there were no such profits) for the purposes of Part 9A of TIOPA 2010 (controlled foreign companies).

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